[ROUGH DRAFT] Developing Organizational Policies on Web Accessibility

Note: This document is a rough draft in
development, and should not be referenced or quoted under any circumstances.
Current approved information is at www.w3.org/WAI/impl/pol
Last updated: $Date: 2008/11/24 20:38:04 $ [analysis & changelog]

This page is part of a resource
suite that recommends strategies and best practices for organizations
planning to adopt Web Content Accessibility Guidelines (WCAG) or updating to
WCAG 2.0 from WCAG 1.0.Whether your organization is adopting its first Web
accessibility policy, considering updating from WCAG 1.0 to WCAG 2.0, or
migrating to WCAG from other standards, this document addresses
considerations that can arise when developing or revising your organization's
policies on Web accessibility. The following sections address considerations
in setting organizational policy in more detail by:

Explaining how to identify legal and policy factors that apply to your
organization

Because governmental policies
exist that apply to some kinds of Web sites in some countries,
organizations should ensure that their policies at least require the minimum
accessibility mandated by any policies that already apply to their sites.
Legal and policy factors apply differently to specific organizations and
situations. For example, one organization might be required by explicit
government regulations to make its Web sites accessible, while another
organization follows the Web accessibility policies recommended by its trade
association or required by a partner company.

To understand legal and policy implications for transitioning your Web
content to WCAG version 2, you first must know what policies apply to your
organization. For guidance, the following questions can help you identify how
the legal and policy aspects of Web accessibility apply to the
organization:

If the organization:

Is required by law or other legal mandate to make its Web site
accessible, or

Provides Web content or software to clients who are required by law or
other legal mandate to make their Web sites accessible

If so, then clarify whether the policy explicitly targets an existing Web
accessbility standard or guideline, its version, and a level of conformance.
For example, the Canadian
Look and Feel Standards targets WCAG version 1, Priority 1 and 2, with an
effective date of January 1, 2007.

If conformance to U.S. Section 508 is required, meeting WCAG 2.0 Level
A will achieve this goal.

If conformance to WCAG version 1, Priority 1 and 2 is required, ask the
administrative body to consider moving to WCAG version 2, Level AA as a
meets-or-exceeds threshold

If you are uncertain whether your organization is subject to Web
accessibility policies or legislation, see Determining
Applicable Policies. Once you have confirmed the applicable policies, you
should also question:

Are the requirements adequate to meet the needs of people with
disabilities?If the required guidelines might not adequately meet the needs
of the Web site's users with some disabilities, the organization can
include in its business case additional guidelines it chooses to meet.
See Considerations Beyond
Requirements.

Are there specified guidelines, conformance levels, and dates
for compliance?For example, does the policy state that a certain level of
compliance is required by one date, and a higher level of compliance is
required by a later date? See Considerations for the Future.

Will policies later become applicable?
For example, requirements might be in development now that will be
enforced in the future; or, an organization might expand into countries
or other markets where Web accessibility policies already apply. See Considerations for the Future.

Does the organization understand the risks of failing to
provide accessible Web sites?In some cases it is useful to include in a business case the
negative impact on reputation and potential legal costs associated with
defending against legal action for not complying with Web accessibility
requirements. See Understanding Risks for
Non-Compliance.

Is the organization subject to multiple sets of guidelines or
policies?
If the organization operates is global, its Web content may be subject to
multiple Web accessibility policies and standards. For strategies to meet
this variety, see Addressing Multiple
Standards.

Web accessibility requirements can be in the form of policies, laws,
regulations, standards, guidelines, directives, communications, orders, or
other types of documents. Policies Relating to Web Accessibility lists governmental
legislation and related information for many countries and regions.

Some governments have laws that specifically require that
certain types of Web sites are accessible. Others might not directly specify
Web accessibility, yet the Web is indirectly covered under
broader anti-discrimination legislation, information and communications
technology policy, or other laws or policies.

An organization might be required by non-governmental
policies to make its Web site accessible, such as a university Web
accessibility policy that requires department Web sites be accessible.
Sometimes organizations are compelled to meet other policies, such as
policies from trade or industry associations, professional associations, or
standards organizations.

Considerations for
Different Types of Organizations

Government -
Some governmental Web accessibility requirements apply only to national
government ministries' or agencies' Web sites; some also apply to
provincial or state governments. Some other levels of government, such as
provincial or state, establish requirements independent of national
requirements.

Education - Many
educational institutions and organizations are covered by governmental
requirements for accessibility of Web-based educational resources and
online learning environments. In some countries or regions, educational
institutions are covered in broad policies along with other types of
organizations; and in others there are policies specifically addressing
educational institutions. In addition to governmental requirements, some
educational institutions and organizations have established separate or
more extensive requirements for accessibility. In some cases there is a
specific policy on Web accessibility; in other cases Web accessibility is
covered under broader accessibility policies.

Industry and Non-Governmental
Organizations (NGO) - Some government policies require industry
and NGO Web sites to be accessible. These types of organizations might
also choose to follow other Web accessibility policies, such as
recommendations from trade (industry) associations or professional
associations. Many corporations and NGOs establish their own policies for
Web accessibility, which are often more extensive than those required by
government policies. In some cases, policies established by corporations
or NGOs might also apply to subsidiaries, vendors, and others who do
business with the organization.

Sometimes the required standards or minimum conformance level might not
adequately meet the needs of the Web site's users with disabilities. If the
needs of people with some disabilities are left out of the required
accessibility standards, an organization might choose to meet additional
guidelines in order to provide sufficient accessibility. Version 2 of the
WCAG guidelines may cover a wider range of disabilities, and so conformance
to version 2 may help the organization meet these users' needs.

It is almost always significantly easier, more effective, and less
expensive to incorporate accessibility early in Web site development or
redesign, rather than retrofit existing sites later. Therefore, many
organizations that might be subject to Web accessibility requirements in the
future choose to incorporate Web accessibility as soon as feasible.

An organization might be subject to additional Web accessible requirements
in the future because:

Policies in development will apply to the organization

The organization expands into countries or other markets where Web
accessibility policies apply

The organizations' existing customers may partner with or be acquired
by organizations with corporate Web accessibility policies.

Some policies reference specific guidelines or standards for Web
accessibility and include dates for compliance. For example, a policy might
state that Web sites meet Web Content Accessibility Guidelines (WCAG) Level A by a certain date and WCAG
Level AA checkpoints by a later date. However, an organization might
determine that it is most efficient to address all the requirements at the
same time.

Once the applicable policies are understood, your organization should
understand the risks of non-compliance with those policies. For example, some
organizations have faced legal action for not making their Web sites
accessible. Not complying with accessibility requirements can result in
significant legal costs and have negative impact on the organization's
reputation. At times, the legal requirements for an organization might be
unclear. In such cases, some organizations determine that it is in their best
interest (financially and otherwise) to make their sites accessible, rather
than risk legal action.

As described above, an organization may be subject to multiple Web
accessibility policies; for example, standards from governments in different
counties where they operate, from a trade association, and from a partner
organization. Addressing different standards is more complex than addressing
a single standard; however, because there is almost always significant
overlap between standards, the work to meet two different standards is not
twice the work to address one standard. In most cases an organization meeting
the more comprehensive standard can easily ensure that other standards are
also met.

For organizations that are concerned about meeting multiple standards, it
can be effective to include in the business case detail on the overlap
between standards. For example, an appendix that shows the similarities
between the different standards can illustrate where it is not much more
effort to meet multiple standards.

Fortunately for Web authors, version 2 of WCAG was developed
simultaneously with other standards updates. When the Telecommunications and
Electronic and Information Technology Advisory Committee (TEITAC) reviewed
the original Section 508 guidelines, they did so with consideration of WCAG
and other Web accessibility standards.Â The committee’s membership
included representatives from industry, disability groups, individuals
contributing to the WCAG version 2 update and others working on European
based Web standards. The effect of this effort has been to harmonize
standards. With WCAG version 2, Level AA, adopters can be assured of meeting
or nearly meeting myriad other Web accessibility standards.

Organizational policies can be very simple, or very comprehensive. In
either case, your policy should identify the standard and its version to
which the organization commits to conform. For example, a simple policy might
state:

"[This organization] is committed to ensuring accessibility of its Web site
for people with disabilities. New and updated Web content produced by our
organization will conform to W3C/WAI's Web Content Accessibility Guidelines 2.0, Conformance Level A, by
[date]. Existing Web content produced by our organization, and new,
updated, and existing Web content provided for our site by third-party
developers, will conform to Conformance Level Double A by [date]. We will
initiate an internal monitoring program by [date]. Vendors supplying
software used to develop our site will be required to provide information
by [date] on conformance to W3C/WAI's Authoring Tool Accessibility Guidelines 2.0, Conformance Level A. Our
home page and our 'about this site' page will include links to this policy.
We will review this policy in the future to consider updating it to an
advanced version of W3C's Web Content Accessibility Guidelines once
available."

The following sections describe the steps to develop your Web
accessibility policy in greater detail.

The term "WAI Guidelines" is non-specific; it can refer to any one of the
three accessibility guidelines produced by W3C/WAI. In addition, it can refer
to either the current version (2.0) or the previous version (1.0). Provide a
clear reference to the specific guidelines document and its version with
which conformance is expected:

Version 2 of these guidelines are currently in varying states of
completion. WCAG 2 will reach technical recommendation first; ATAG and UAAG
are each currently in working draft stage. Organizations wishing to require
conformance to WCAG 2.0 once that becomes a W3C Recommendation may specify
conformance to the "Web Content Accessibility Guidelines" without specifying
a version number.

Specify an expected level of conformance for Web site(s). For example:

"Conformance to WCAG 2.0 Level A" sets the expectation that a Web
site would fulfill all priority one checkpoints, which address
absolute barriers to accessing content on a Web site.

"Conformance to WCAG 1.0 Double A" sets the expectation that a Web
site would fulfill all priority one and priority two checkpoints,
which address absolute and substantial barriers to accessing content
on a Web site.

"Conformance to WCAG 1.0 Triple A" sets the expectation that a Web
site would fulfill all priority one, two, and three checkpoints,
which address absolute, substantial, and minor barriers to accessing
content on a Web site.

Specify an expected level of conformance for authoring tools used by
the organization, or by third party developers, to produce content for
the organization's Web site.

"Conformance to ATAG 1.0 Level A" sets the expectation that Web
authoring software acquired by an organization can fulfill all
priority one checkpoints for accessibility of the software user
interface and support for production of accessible content. [See
example under "#5 Set milestones" below.]

[To add to terms of subcontract]: "[Subcontracted Web developer]
will consider the use of ATAG 1.0 conformant software where
available. If not using ATAG 1.0 conformant authoring tools,
[subcontracted Web developer] will ensure that all content and
templates generated for [this organization's] production of content
is WCAG 1.0 Double A -conformant, and contains no markup that will
interfere with generation of WCAG 1.0-conformant content.

Specify to what extent this organization's requirements should apply to
new, updated, and existing Web pages. For example:

"This policy applies to all new, updated, and existing Web pages."

Specify to what extent requirements should apply to Web pages provided
by a third-party (subcontractor, or other information provider, but as
part of main site). The Web site's users may need access to primary and
to third-party content equally. It may take additional effort to educate
and get compliance from third-party content developers. For example:

"This policy applies to all Web content produced or updated by
[this organization]. In addition, [this organization] is taking the
following steps to ensure accessibility of content provided by
third-party developers [NOTE that for some sites, accessibility of
third-party content may be essential to complying with government
policy]:

In some cases it may be practical to phase in accessibility by
addressing all of priority one checkpoints rapidly, since these can be
absolute barriers if unaddressed; then phasing in priority two
checkpoints with the next round of site improvements [no later than a
specified date]; with priority three checkpoints left as optional. For
example:

Consider how to address questions of priorities that may arise
especially for Web sites with a large number of pages. Do not make
assumptions about which areas of a Web site or which Web services people
with disabilities are interested in or not. For example:

"This policy applies to all areas of this organization's internal
and external Web sites, including legacy content."

Or, "This policy applies to all areas of this organization's
internal and external Web sites, with priority to [specify which
areas] areas of the site; however, all areas of the site are expected
to conform to [specify conformance level] by [second date].

Consider setting date(s) for accessibility support in software. For
example:Â

"By [first date], all vendors of authoring tools used by [this
company] should provide information regarding their plans for ATAG
1.0 conformance in future versions of their software. By [second
date] [this company] will preferentially purchase ATAG 1.0-conformant
authoring tools."

Consider setting dates for browser and multimedia conformance, without
restricting people's ability to use adaptive browsers.

"By [date], all vendors of browsers and multimedia players used by
[this company] should provide information regarding their plans for
UAAG 1.0 conformance in future versions of their software.Â By [second
date] [this company] will preferentially purchase UAAG 1.0-conformant
browsers and multimedia players.

Specify a recommended process and schedule for reviewing the
organization's Web site for accessibility. For example:

"Each department will review all areas of the organizations' Web
site under its control using the process described at Evaluating Web Sites
for Accessibility, and will review all new material that it
publishes by using the same process."

Each section of the Web site will include links for feedback on the
site; this information will be compiled and considered during the
review process."

Specify whether or not conformant pages, or sections of a Web site,
should be labeled as such. For example:

"The introductory page for sections of the Web site that have been
determined to be conformant according to [link] process should
display the [WCAG 2.0 Double A logo] or bear the following statement
["this page conforms to..."]

Consider specifying a periodic review of areas of the Web site by an
internal department with the authority to follow up on non-conformant
areas of the Web site. For example:

"[This organization] will conduct periodic reviews of the Web site
and any department with non-conforming Web pages will be asked to
correct the problem within two weeks. Further problems in
accessibility of an area will result in [specify as appropriate]"

If you already reference WCAG 1.0, specify a process and schedule for
identifying needed updates to conform to WCAG 2.0. Web sites that meet
WCAG 1.0 - Level 2 are already very close to meeting WCAG 2.0 - Level AA.
To understand the differences, see Comparision of
WCAG 1.0 Checkpoints to WCAG 2.0. For example:

"Over the next quarter, [this organization] will update the Web
site to comply with WCAG 2.0."

Provide a mechanism for site visitors to report accessibility issues
they experience. Provide a means to capture the location where the issue
occurred.

If the organization has or is developing an overall policy for Web
sites, for instance establishing best practices for use of Web standards,
support for a privacy policy, internationalization, use of metadata,
usability, etc., incorporating accessibility in the overall policy can be
efficient, rather than establishing accessibility as a stand-alone
policy.

Organizations currently referencing WCAG 1.0 should review their
current policy and update it to WCAG 2.0. Communicating the similarity of
version 1 and version 2 may make updating the policy easier within the
organization.